INTERFACE DEVELOPMENT AND TESTING AGREEMENT

1 CMEGLOBEX_IFDevelopmentAgmt_062118 INTERFACE DEVELOPMENT AND TESTING AGREEMENT This INTERFACE DEVELOPMENT and TESTING AGREEMENT (this AGREEMENT ) is effective as of _____ (the Effective Date ), is entered into between _____, organized and existing under the laws of _____, with its principal place of business at _____ (the Company ), and Chicago Mercantile Exchange Inc., a Delaware corporation, with its principal place of business at 20 South Wacker Drive, Chicago, Illinois 60606, ( CME ). This AGREEMENT consists of the following Schedules: Terms and Conditions Schedule A Certification Environment Access Request and Information Form Schedule B BACKGROUND. CME maintains and operates various electronic interfaces and systems including but not limited to CME Globex, CME ClearPort, CME Direct, ConfirmHub, Risk Management INTERFACE , Front End Clearing, Drop Copy and CME Account Manager ( CME Interfaces ) and allows entities to develop and test a Customer INTERFACE (as defined below) to a CME INTERFACE .

2 This AGREEMENT governs the relationship between CME and Company with respect to Company s DEVELOPMENT and TESTING of a Customer INTERFACE . IN WITNESS WHEREOF, the parties have caused their duly authorized representatives to execute this AGREEMENT as of the Effective Date. COMPANY Signature: Name: Title: Date: CHICAGO MERCANTILE EXCHANGE INC. Signature: Name: Title: Date: UK DATA PROTECTION ACT 1998. Companies within the United Kingdom acknowledge that CME collects, maintains, and processes data regarding its customers in one or more databases and, in the ordinary course of business, may transfer such data outside the European Union. Such customers hereby consent to the transfer of such data outside of the European Union. Occasionally, we may tell you about other products or services offered by Chicago Mercantile Exchange Inc.

3 That we believe may be of interest to you. If you would prefer not to receive such communications from CME, please check this box: CMEGLOBEX_IFDevelopmentAgmt_062118 2 SCHEDULE A TO INTERFACE DEVELOPMENT AND TESTING AGREEMENT TERMS AND CONDITIONS Certification Access Method means the manner inwhich Company and any Company Authorized Users access the Certification Environment, as selected by Company in Schedule B. B. Certification Environment means the electronicenvironment provided by CME to develop, test, and maintain a Customer INTERFACE to current or future versions of a CME INTERFACE . C. Clearing Firm means an entity that, in accordancewith CME Rules (or, if applicable, the rules, policies and procedures of a Participating Exchange), is authorized to clear trades entered into a CME INTERFACE , and that is a member in good standing of CME s (or, if applicable, a Participating Exchange s) Clearinghouse.

4 D. CME Interfaces has the meaning set forth in theBackground section of this AGREEMENT . E. CME Materials has the meaning set forth in of this CME Rules means the rules, policies and proceduresof CME, as such rules are established and modified by CME from time to time. G. CME Trademarks means the CME trade names,trademarks, service names, brand names or logos used in connection with the CME Interfaces, including without limitation, CME Group, Chicago Mercantile Exchange, CME, Globex, iLink, CME s globe design, ClearPort, and CME Direct. H. Company Authorized User means any authorizeduser who accesses the Certification Environment via the Certification Access Method. I. Customer means a customer of Company, ifapplicable, who is authorized to use the Customer INTERFACE to access a CME INTERFACE .

5 J. Customer INTERFACE means the systems interfacesoftware or the front-end INTERFACE software (automated or otherwise) created by either Company or a third party that allows Company s systems or Company s clients systems, if applicable, to interact with a CME INTERFACE . K. Drop Copy means a risk management application inwhich copies of CME Globex order entry responses are delivered to subscribing Customers via an alternate FIX connection. L. Equipment means, if applicable, the computerterminals, micro-computers, software programs or other user INTERFACE devices used by either party as part of the Certification Access Method. Equipment provided by CME is CME Equipment. Equipment provided by Company is Company Equipment. M. Fees means, if applicable, the fees payable byCompany to CME for access to the Certification Environment, as set forth in Exhibit , and as such fees may be modified from time to time by CME in accordance with Section 8 of this AGREEMENT .

6 N. GCC means the CME Global Command Center, thecenter in Chicago, Illinois and such other centers as shall from time to time be established by CME to support market operations and control trading and/or clearing through a CME INTERFACE . O. Installation Date means, for the applicable Premisesand for the applicable Certification Access Method, the date that CME or its designee completes network service acceptance TESTING . P. Market Data means certain information and datapertaining to Products and other financial instruments, which Company may obtain access to via the Certification Environment. Market Data may include opening and closing range prices, high-low prices, settlement prices, current bid and ask prices, last sale prices, price limits, requests for quotations, estimated and actual contract volume data, text messages pertaining to market activity, contract specifications, fast or late messages, information respecting exchange-for-physical (EFP) and against actuals (AA) transactions, and any information and data that are derived from or substantially equivalent to the foregoing.

7 Q. Participating Exchange(s) means those exchangeswhose Products may be traded and/or cleared through a CME INTERFACE . R. Person means an individual, corporation, partnership,trustee, trust, regulatory body or agency, government or governmental agency or entity (however designated or constituted) or any unincorporated organization. S. Premises means, if Company has a direct connectionpursuant to Schedule B, the location(s) where Company has access to the Certification Environment. CMEGLOBEX_IFDevelopmentAgmt_062118 3 T. Products means all contracts and other listed itemsthat may be traded or cleared through a CME INTERFACE as determined by CME and any Participating Exchanges from time to time. AND TESTING OF to Access Certification Environment. Subjectto the terms and conditions of this AGREEMENT , CME grants to Company a non-exclusive, nontransferable, revocable license (without the right to grant sublicenses), during the term of this AGREEMENT , to electronically connect to the Certification Environment solely for the purpose of developing and maintaining a Customer INTERFACE .

8 Company s right to access the Certification Environment hereunder is defined by the terms of this AGREEMENT and Company shall not attempt to access the Certification Environment except as expressly permitted under this AGREEMENT . to Access Market Data. Subject to the termsand conditions of this AGREEMENT , CME grants to Company a non-exclusive, nontransferable, revocable license (without the right to grant sublicenses), during the term of this AGREEMENT , to receive and use Market Data solely for purposes of developing maintaining, and marketing the Customer INTERFACE , but Company shall not otherwise distribute, sublicense or resell the Market Data. As part of and in no way limiting the forgoing license, Company may store and distribute (but shall not resell) historical Market Data to Company s clients and potential clients for training and marketing purposes provided such Market Data is not used for live trading, and further provided such Market Data is not redistributed by such clients or potential clients to other third parties.

9 Procedures. This Section 2(C) shall notapply if a third party provides Customer INTERFACE to Company. (i) DEVELOPMENT Work. Except for the services provided by CME that are expressly described in Sections 2(C)(iii) and (iv), Company will be responsible, at its own expense, for conducting all design, DEVELOPMENT and maintenance work in connection with its Customer INTERFACE . This work includes, but is not limited to, the purchase, installation and maintenance of all hardware and software necessary to design, develop, test and maintain the Customer INTERFACE and the DEVELOPMENT and maintenance of any source or object code constituting or relating to the Customer INTERFACE . (ii)Connectivity. Company is required to install andmaintain, at its expense and in accordance with instructions and specifications provided by CME from time to time, a VPN data connection through a local exchange carrier or network service provider.

10 Company may use such data connection for DEVELOPMENT and DEVELOPMENT TESTING of the Customer INTERFACE . Company is required to use such data connection to complete all portions of the certification TESTING of the Customer INTERFACE described in Section 2(E). (iii) System Administration. CME will provide Company with IP addresses and user accounts for Company s dedicated use during the DEVELOPMENT and DEVELOPMENT TESTING of its Customer INTERFACE and the certification TESTING described in Section 2(E). (iv) DEVELOPMENT Support. CME will use commercially reasonable efforts to support Company s DEVELOPMENT efforts by ensuring that CME staff members or consultants are reasonably available during CME s regular business hours to answer questions and provide other reasonable assistance to Company.